Supreme Court of Arkansas

State v. West

April 17, 20142014 Ark. 174

Summary

The court held that the State's appeal was proper because the forfeiture proceeding was civil and independent of any criminal prosecution. It further held that naming West as a defendant in the complaint's caption required personal service, and that publication by warning order did not establish personal jurisdiction because the State did not show a diligent inquiry into her identity or whereabouts. The court affirmed the dismissal of the action against West.